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News & Press: Social Justice

NASW-Michigan Jointly Submits Comments Against Detention of Children with MIRC

Sunday, November 25, 2018   (0 Comments)
Posted by: Allan Wachendorfer
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November 6,2018

Submitted via

Debbie Seguin Assistant

Director Office of Policy

U.S. Immigration and Customs Enforcement

Department of Homeland Security

500 12th Street, SW.

Washington, DC 20536

RE: DHS Docket No. ICEB-2018-0002, RIN 0970-AC42 1653-AA75, Comments in

Response to Proposed Rulemaking: Apprehension, Processing, Care, and Custody of Alien Minors and Unaccompanied Alien Children

Dear Assistant Director Seguin:

The Michigan Immigrant Rights Center (“MIRC”) in collaboration with the National Association of Social Workers (“NASW”) Michigan Chapter and Vivek Sankaran, Clinical Law Professor at the University of Michigan Law School write in response to the Department of Homeland Security to express our strong opposition to the proposed rule to amend regulations relating to the apprehension, processing, care, custody, and release of alien juveniles published in the Federal Register on September 7,2018.

MIRC is a legal services provider and resource center for Michigan’s immigrant communities. MIRC has been representing unaccompanied children in foster care in Michigan for almost 10 years. It has represented children who have been separated from their parents at the border and children and youth who have traveled to the United States on their own — unaccompanied minors. Over the past year alone, MIRC has represented more than 280 children in immigration matters. The NASW Michigan Chapter is a membership organization for professional social workers in the state of Michigan. Their nearly 6,000 members practice in every county in Michigan. Their parent national organization and affiliated state chapters boast over 110,000 members. Most of them work in the areas of child welfare, foster care, trauma, and mental health for families and children. As social workers, they are intimately aware of the human impact of trauma both through practice and academic research. Vivek Sankaran is a clinical law professor at the University of Michigan Law School whose practice involves representing children in the foster care system.

Together, we strongly oppose the proposed changes to the Flores Settlement Agreement. For the reasons set forth in the comment that follows, the Department of Homeland Security and the Department of Health and Human Services should immediately withdraw its current proposal, and instead dedicate their efforts to ensure robust, good-faith compliance with the Flores Settlement Agreement.


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